DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-85,287

QUAD/GRAPHICS MARKETING, LLC
MARENGO DIVISION
A SUBSIDIARY OF QUAD/GRAPHICS, INC.
INCLUDING ON-SITE LEASED WORKERS FROM
LABOR READY MIDWEST, INC. AND MANPOWER
MARENGO, IOWA

Notice of Negative Determination
After Statutory Reconsideration

As required by the Trade Adjustment Assistance Reauthorization
Act of 2015 (TAARA 2015), which was enacted as Title IV of the
Trade Preferences Extension Act of 2015, Public Law No. 114-27,
section 405(a)(1)(A), the investigation into this petition was
reopened for a reconsideration investigation to apply the
requirements for worker group eligibility under chapter 2 of title
II of the Trade Act of 1974, as amended by the TAARA 2015, to the
facts of this petition (statutory reconsideration).
The initial investigation, initiated on May 6, 2014, resulted
in a negative determination, issued on September 12, 2014, that was
based on the Department’s findings that the subject firm did not
shift production of inserts to a foreign country and that neither
the subject firm nor its customers increased imports of like or
directly competitive articles. The determination was applicable to
workers and former workers of Quad/Graphics Marketing, LLC,
Marengo Division, a subsidiary of Quad/Graphics, Inc., Marengo,
Iowa (“Quad Graphics Marketing, LLC” or “subject firm”). The
workers’ firm is engaged in activities related to the production of
retail inserts. The subject worker group includes on-site leased
workers from Labor Ready Midwest, Inc. and Manpower.
Based on information reviewed during the reconsideration
investigation, the Department determines that the requirements for
certification have not been met.
With respect to Section 222(a)(2)(A)(ii) of the Act, the
investigation revealed that imports of articles like or directly
competitive with retail inserts produced by Quad/Graphics
Marketing, LLC have not increased during the relevant period.
Neither the subject firm nor its major declining customers
increased imports of retail inserts, or like or directly
competitive articles, during the twelve month period prior to the
petition date.
With respect to Section 222(a)(2)(B) of the Act, the
investigation revealed that the subject firm did not shift the
production of retail inserts, or a like or directly competitive
article, to a foreign country or acquire such production from a
foreign country.
With respect to Section 222(b)(2) of the Act, the
investigation revealed that Quad Graphics Marketing, LLC is not a
Supplier or Downstream Producer to a firm that employed a group of
workers who received a certification of eligibility under Section
222(a) of the Act, 19 U.S.C. § 2272(a).
Finally, the group eligibility requirements under Section
222(e) of the Act, have not been satisfied either because Criterion
(1) has not been met since the workers’ firm has not been publicly
identified by name by the International Trade Commission as a
member of a domestic industry in an investigation resulting in an
affirmative finding of serious injury, market disruption, or
material injury, or threat thereof.
Conclusion
After careful review, I determine that the requirements of
Section 222 of the Act, 19 U.S.C. § 2272, have not been met and,
therefore, deny the petition for group eligibility of Quad/Graphics
Marketing, LLC, Marengo Division, a subsidiary of Quad/Graphics,
Inc., including on-site leased workers from Labor Ready Midwest,
Inc. and Manpower, Marengo, Iowa, to apply for adjustment
assistance, in accordance with Section 223 of the Act, 19 U.S.C. §
2273.
Signed in Washington, D.C. this 23rd day of March, 2016

/s/ Del Min Amy Chen
______________________________
DEL MIN AMY CHEN
Certifying Officer, Office of
Trade Adjustment Assistance





DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-85,287

QUAD/GRAPHICS MARKETING, LLC
MARENGO DIVISION
A SUBSIDIARY OF QUAD/GRAPHICS, INC.
INCLUDING ON-SITE LEASED WORKERS FROM
LABOR READY MIDWEST, INC. AND MANPOWER
MARENGO, IOWA

Negative Determinations Regarding Eligibility
To Apply for Worker Adjustment Assistance
And Alternative Trade Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended ("Act"), 19 U.S.C. § 2273, the Department of Labor
herein presents the results of an investigation regarding
certification of eligibility to apply for worker adjustment
assistance.
Workers of a firm may be eligible for worker adjustment
assistance if they satisfy the criteria of subsection (a) and
(b) of Section 222 of the Act, 19 U.S.C. § 2272(a) and (b). For
the Department of Labor to issue a certification for workers
under Section 222(a) of the Act, 19 U.S.C. § 2272(a), the
following three criteria must be met:
(1) The first criterion (set forth in Section 222(a)(1) of the
Act, 19 U.S.C. § 2272(a)(1)) requires that a significant
number or proportion of the workers in such workers' firm,
or an appropriate subdivision of the firm, have become
totally or partially separated, or are threatened to become
totally or partially separated;
(2) The second criterion (set forth in Section 222(a)(2) of the
Act, 19 U.S.C. § 2272(a)(2)) may be satisfied in one of two
ways:
(A) Increased Imports Path:
(i) sales or production, or both, at the workers' firm
must have decreased absolutely, AND
(ii) imports of articles like or directly competitive with
articles produced by such firm or subdivision have
increased; and
(iii) the increase described in clause (ii) contributed
importantly to such workers' separation or threat of
separation and to the decline in the sales or
production of such firm or subdivision.
(B) Shift in Production Path:
(i) there has been a shift in production by such workers'
firm or subdivision to a foreign country of articles
like or directly competitive with articles which are
produced by such firm or subdivision; and
(ii)(I) the country to which the workers' firm has
shifted production of the articles is a party to a
free trade agreement with the United States;
(II)the country to which the workers' firm has
shifted production of the articles is a beneficiary
country under the Andean Trade Preference Act, African
Growth and Opportunity Act, or the Caribbean Basin
Economic Recovery Act; or
(III)there has been or is likely to be an increase
in imports of articles that are like or directly
competitive with articles which are or were produced
by such firm or subdivision.

For the Department to issue a certification under Section
222(b) of the Act, 19 U.S.C. § 2272(b), to workers of a Supplier
or a Downstream Producer, the following criteria must be met:
(1) a significant number or proportion of the workers in
the workers' firm or an appropriate subdivision of the
firm have become totally or partially separated, or
are threatened to become totally or partially
separated;
(2) the workers' firm is a Supplier or Downstream Producer
to a firm that employed a group of workers who
received a certification of eligibility under Section
222(a) of the Act, 19 U.S.C. § 2272(a), and such
supply or production is related to the article that
was the basis for such certification; and
(3) either
(A) the workers' firm is a supplier and the component
parts it supplied to the firm described in paragraph
(2) accounted for at least 20 percent of the
production or sales of the workers' firm; or
(B) a loss of business by the workers' firm with the firm
described in paragraph (2) contributed importantly to
the workers' separation or threat of separation.

Section 222(c) of the Act, 19 U.S.C. § 2272(c), defines the
terms "Supplier" and "Downstream Producer."
The investigation was initiated in response to a petition
filed on May 6, 2014 by a State Workforce Agency on behalf of
workers of Quad/Graphics Marketing, LLC, Marengo Division, a
subsidiary of Quad/Graphics, Inc., Marengo, Iowa (Quad
Graphics Marketing, LLC or subject firm). The workers' firm is
engaged in activities related to the production of printing and
binding of retail inserts. The worker group includes on-site
leased workers from Labor Ready Midwest, Inc. and Manpower.
The petition states that a "Separations occurring at the
Marengo plant may have a connection to international trade."
During the course of the investigation, information was
collected from the workers' firm and its major declining
customers.
With respect to Section 222(a)(2)(B) of the Act, the
investigation revealed that Quad/Graphics Marketing, LLC did not
shift the production of printing and binding of retail inserts,
or like or directly competitive articles, to any foreign
country.
With respect to Section 222(a)(2)(A)(ii) of the Act, the
investigation revealed that that Criterion (2)(A)(ii) has not
been met because imports of articles like or directly
competitive with printing and binding of retail inserts
produced by Quad/Graphics Marketing, LLC have not increased
during the relevant period. The subject firm did not report
increased imports of printing and binding of retail inserts, or
like or directly competitive articles, and the Department's
customer survey did not reveal increased imports of printing and
binding of retail inserts, or like or directly competitive
articles.
With respect to Section 222(b)(2) of the Act, the
investigation revealed that Quad/Graphics Marketing, LLC is
not a Supplier or Downstream Producer to a firm that employed a
group of workers who received a certification of eligibility
under Section 222(a) of the Act, 19 U.S.C. § 2272(a).
In order for the Department to issue a certification of
eligibility to apply for alternative trade adjustment assistance
(ATAA), the worker group must be certified eligible to apply for
trade adjustment assistance (TAA). Since the workers are denied
eligibility to apply for TAA, the workers cannot be certified
eligible for ATAA.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that all workers of Quad/Graphics
Marketing, LLC, Marengo Division, a subsidiary of
Quad/Graphics, Inc., including on-site leased workers from
Labor Ready Midwest, Inc. and Manpower, Marengo, Iowa, are
denied eligibility to apply for adjustment assistance under
Section 223 of the Trade Act of 1974, as amended, and are also
denied eligibility to apply for alternative trade adjustment
assistance under Section 246 of the Trade Act of 1974, amended.
Signed in Washington, D.C. this 12th day of September, 2014


/s/Del Min Amy Chen
______________________________
DEL MIN AMY CHEN
Certifying Officer, Office of
Trade Adjustment Assistance